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Washington National Tax Services newsletter archive
This publication provides timely insight and analysis on emerging tax issues. Developed by professionals in PwC's Washington National Tax Service, WNTS Insight keeps you "in the know" with respect to the significant tax developments impacting your company in today's ever-changing legislative and regulatory environment — a must read for corporate tax professionals wanting to stay ahead of the curve.
May 2013
- Final regulations on deemed asset sale elections offer taxpayers more flexibility
- IRS issues safe harbor ‘repairs’ guidance for electric generation
- Numerous business tax reform proposals included in report to Ways and Means Committee
- IRS issues favorable guidance on certain transaction costs
- Joint Tax Committee staff issues report on Ways and Means tax reform working groups
April 2013
- The IRS provides mixed Section 199 guidance on US government contracts
- Taxpayer could claim bonus depreciation by filing accounting method change
- Modified LB&I directive addresses revised effective dates for ‘temporary repairs regulations’
- Obama Administration FY 2014 budget focuses on tax reform, deficit reduction, and new initiatives
- Minimum royalties must be capitalized to ending inventory, IRS concludes
- Employee separation payments do not qualify for research credit, IRS concludes
- Taxpayers may continue to accelerate certain AMT credits
- Publisher’s pre-production development activities held not Section 199 manufacturing activities
March 2013
- Senate Budget Committee calls for tax increase; Senate Finance Committee prepares for tax reform
- House Ways and Means Committee releases pass-through tax reform discussion draft
- House Republican budget calls for business and individual tax reform
- New GLAM helps clarify IRS position on consolidated group ‘end-of the-day’ and ‘next-day’ rules
February 2013
- Final noncompensatory partnership option rules could affect wide range of arrangements
- General Asset Accounts: Considerations in preparing 2012 returns
- Ways and Means "Discussion Draft" proposes major changes to taxation of financial products
- OECD "base erosion and profit shifting" report looks to action plan
- Tax treaty update: Several key pacts awaiting Senate approval
January 2013
- Challenges ahead for tax policy - 2013 Tax Legislative Outlook
- Ways and Means Chairman Camp releases discussion draft for financial products tax reform
- Fiscal cliff legislation extends research credit, resolves M&A-related credit issue
- Guidance on accounting for assets: What companies need to know about single, multiple, and general asset accounts
- New tax law extends business tax incentives
- Congress passes fiscal cliff agreement to extend tax rates for incomes below $450,000; deal includes business "tax extenders"
December 2012
- Fiscal cliff differences remain unresolved as 2012 year-end approaches
- IRS relaxes requirements for reclassifying workers as employees
- IRS formally delays effective date of the temporary repairs regulations
- IRS releases taxpayer-favorable guidance on examination of research expenditures in pharmaceutical sector
- Recent OECD transfer pricing initiatives portend significant consequences for multinationals
- Required payments of estimated tax delayed for victims of Hurricane Sandy
- Proposed regulations clarify scope and application of new net investment income tax
November 2012
- IRS examines whether manufacture of packaging qualifies for section 199 deduction
- IRS issues guidance related to final "repairs" regulations and delay of effective date
- New IRS/Treasury "business plan" calls for important research credit guidance
- Employers may provide tax-free relief to victims of Hurricane Sandy
- 2012 election results point to continued divisions over tax policy
October 2012
- UN transfer pricing guidance for developing countries could increase burdens on multinationals
- IRS provides guidance to employers on wage characterization arrangements
- Court rejects research credit claim for customization and configuration of software
- IRS explains key definitions for complying with healthcare law
- Tax issues and opportunities in technology litigation judgements and settlements
September 2012
- IRS rules that certain milestone payments are not success-based fees
- Second Circuit examines eligibility of supplies for research credit
- Sixth Circuit rules for taxpayer in important severance payment employment tax case
- Key business and individual tax issues remain uncertain in advance of November elections
- Proposed rules on "negative additional section 263A costs" would require many producers to change their UNICAP method
August 2012
- Second Circuit affirms taxpayer win in interest-netting case
- Top automatic accounting method changes for 2011 returns
- IRS issues important guidance on expense reimbursement arrangements
- IRS releases important guidance on personal use of business aircraft
- House approves temporary extension of 2001 and 2003 income tax rates for all individuals; expected to approve expedited process for 2013 tax reform legislation
- Senate Finance Committee approves "tax extenders" bill renewing certain expired and expiring business and individual tax provisions
July 2012
- IRS challenges certain cross-border reorganizations involving intangibles
- Senate bill extending 2001 and 2003 income tax rates for individuals
- Interest capitalization invalidates associated property rule applied to temporarily withdrawn property
- IRS issues guidance on qualification of online software for section 199
- IRS issues adverse interest-netting guidance involving domestic corporation, foreign parent
- Agreement reached on revising US income tax treaties with Japan and Spain; progress made on other US income tax treaties
June 2012
- Final foreign tax credit regulations on overall domestic losses and overall foreign losses provide certainty, flexibility
- Supreme Court upholds health care law; tax provisions remain
- OECD draft intangibles transfer pricing guidelines
- Supreme Court decision could affect tax provisions enacted as part of 2010 health care law
May 2012
- Claims Court: Transfer pricing regulations bar amended return that would reduce taxable income
- IRS LB&I Division to realign domestic operations for greater efficiency
- IRS provides additional guidance regarding limitations on communications between Appeals, Chief Counsel attorneys
- IRS rules favorably on key bonus depreciation issue
April 2012
March 2012
- IRS increases scrutiny of compliance with executive compensation deduction limit
- House Republican budget calls for tax reform; 25-percent top rate for individuals and corporations
- IRS increases scrutiny of nonqualified deferred compensation plans
- WNTS Insight: Accounting method changes under the tangible property regulations: deduction and capitalization of expenditures
- WNTS Insight:Accounting method changes under the tangible property regulations: depreciation and dispositions of property
- IRS releases revenue procedures on accounting method changes relating to the tangible property repair regulations
- IRS revises limitations on communications between Appeals, other IRS staff
February 2012
- District court addresses use of statistical sampling to document business components in research credit case
- Obama Administration releases business tax reform framework
- Final payroll tax reduction agreement reached; does not include full expensing extension
- President Obama's FY 2013 budget includes business and individual tax increase proposals
- IRS releases 2011 Schedule UTP
- Tax Court addresses prepaid service contract issues
- IRS guidance addresses section 199 "benefits and burdens" issues
- IRS clarifies issues related to recurring item exception to economic performance requirement
January 2012
- President Obama outlines tax policy agenda in State of the Union address
- Vodafone's Indian tax case win has important implications for US multinationals
- WNTS 2012 Legislative Outlook: Decision Points for Tax Policy
- The tangible property repair regulations: Plan of rehabilitation, environmental remediation, rotable spare parts, general asset accounts, removal costs, and recovery of certain capital improvements
- The tangible property repair regulations: Acquisition or improvement of property
- The tangible property repair regulations: effective dates, units of property, and dispositions
December 2011
- Final contract manufacturing regulations address key issues for CFCs with branches
- Proposed/temporary tangible capitalization regulations: High-level overview
- IRS releases long-awaited tangible property repair regulations
- New continuity of interest regulations address important issues
- Final cost-sharing regulations provide additional guidance on significant issues
- House passes payroll tax cut extension bill that also would extend bonus depreciation
- Proposed section 382 regulations would provide taxpayer-favorable rules on small shareholders
November 2011
- Final regulations diminish impact of "hot stock" provision, but leave important questions unanswered
- Super Committee unable to reach agreement - fate of expiring provisions remains uncertain
- Court of Federal Claims supports taxpayer on interest-netting issue
- Strict year-end deadline for corporate tentative refund applications
- OECD releases Discussion Draft on interpretation of permanent establishment tests in Model Tax Convention
- Ways and Means Chairman Camp releases Discussion Draft for corporate rate reduction, territorial tax system
October 2011
- Legislative language for Administration's "excess returns" proposal raises issues
- Key year-end planning opportunities for 2011
- Baucus-Hatch bill would make permanent and simplify the research credit
September 2011
- IRS announces voluntary worker reclassification program for employers
- IRS business plan includes guidance on research credit for internal-use software
- LB&I memo provides insights into IRS thinking on use of Schedule UTP during exams
- President Obama proposes $1.5 trillion in new taxes as part of deficit reduction plan; calls for comprehensive tax reform
- IRS business plan includes important corporate tax guidance
- President Obama Proposes $467 Billion in Tax Increases to Offset Cost of Jobs
- President Obama proposes expanded payroll tax relief, extended 100-percent expensing; will propose offsetting deficit reduction measures
- Tax treatment of cloud computing: Resolving the threshold classification issue
- Federal deficits, economic concerns dominate legislative agenda
August 2011
- IRS allows taxpayers use of statistical sampling IRS allows taxpayers greater use of statistical sampling
- New CBO data project reduced deficits, sluggish growth
- Final regulations on post-reorganization accounting method changes modify rules
- IRS focuses on permanent establishment issues; creates combined APA-MAP office
- House passes bill to increase debt limit and reduce future budget deficits; Senate vote expected by August 2
July 2011
- The codified economic substance doctrine: Making decisions in an uncertain world
- Top 10 automatic accounting method changes
- IRS restrictions on research credit elections might lead to 'Mayo' review
- IRS updates Schedule UTP FAQs
- JCT expands analysis of Obama administration proposal for permanent research credit
- Proposed excess compensation regulations reflect continued stricter application of statutory requirements
- Joint audits -- a new approach to cross-border collaboration among tax authorities
June 2011
- JCT analyzes Obama administration proposals on intangibles, excess returns
- Joint Committee on Taxation Issues Report on Revenue Proposals in President Obama's FY 2012 Budget
- Debt limit talks may affect tax reform efforts
- Important guidance on estimating outside stock basis in transferred basis transactions
- Key implications of Tax Court decision in Lattice Semiconductor
May 2011
- Final regs on "Killer B," other triangular reorganizations involving foreign corporations
- IRS guidance on new Schedule M-3 line item for R&D costs
- IRS issues helpful guidance regarding involuntary conversion of inventory in a federally declared disaster
April 2011
- Proposed regulations address deferred losses on intragroup property transfers
- IRS seeks to minimize documentation controversy with safe-harbor election for success-based fees
- President Obama calls for tax reform as part of deficit reduction package
- IRS issues new guidance on health care coverage information reporting
- House Budget Committee Chairman proposes 25-percent top tax rate for individuals and corporations
- IRS makes CAP program permanent, available to more taxpayers
March 2011
- IRS releases guidance on Schedule UTP and policy of restraint
- IRS addresses key issues in new bonus depreciation guidance
- Forthcoming tangible property regulations expected to address several key issues
- Treasury Department provides "Green Book" explanation of Administration FY 2012 tax proposals
- Administration proposes significant changes to worker misclassification relief provisions
- Supreme Court decision addresses deference accorded tax regulations
February 2011
- Key implications of IRS nonacquiescence in Second Circuit analysis of manufacturer's royalty payments
- Tax Court addresses interest-netting issues
- Proposed regulations would provide updated guidance on debt restructuring issue
- Obama Administration proposes FY 2012 federal budget with revenue-raising proposals
- Two recent PLRs address important technical issues under section 382
January 2011
- CBO projects federal budget deficit of nearly $1.5 trillion for fiscal 2011
- President Obama calls for corporate and individual tax reform
- Key issues under temporary 100-percent expensing and extended 50-percent bonus depreciation provisions of 2010 Act
- WNTS 2011 Legislative Outlook: Tax Policy in a Deficit-Driven World
- IRS provides helpful new guidance for accounting method changes
- Canadian Federal Court of Appeal dismisses government's appeal of lower court decision that guarantee fees paid to U.S. parent were deductible
